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DUZER v. COMMISSIONER

Docket No. 25802-88.

63 T.C.M. 1970 (1992)

T.C. Memo. 1992-62

Victor E. Van Duzer and Jane N. Van Duzer v. Commissioner.

United States Tax Court.

Filed February 3, 1992.

Attorney(s) appearing for the Case

Jonathan Cobb Dickey and David S. Foster, 4 Embarcadero Center, San Francisco, Calif., for the petitioners. Steven J. Sibley, for the respondent.

Memorandum Findings of Fact and Opinion

RUWE, Judge:

In a memorandum opinion filed June 5, 1991,1 we decided all the contested issues with respect to respondent's deficiency determinations in petitioners' favor. Subsequent to our opinion, petitioners moved, pursuant to Rule 231,2 for an award of reasonable litigation and administrative costs in the amount of $273,178.49. The issues for decision are...

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